U.S. v. Austin, No. 94-2541 (7th Cir.) (54 F.3d 394) (May 5, 1995) (Judge Joel L. Flaum)
"The Supreme Court held in Dunnigan [U.S. v. Dunnigan, 122 L.Ed.2d 445 (1993)] that when the district court bases a § 3C1.1 enhancement on the defendant's perjury at trial, it should preferably identify each element of perjured testimony, but must at least 'make[] a finding of an obstruction or impediment …
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